G.R. No. L-27594 and L-28144 November 28, 1975
THE DIRECTOR OF LANDS, THE DIRECTOR OF FORESTRY, and the ARMED FORCES OF THE PHILIPPINES, petitioners, vs. HON. SALVADOR C. REYES, as Judge of the Court of First Instance of Nueva Ecija, Branch III, PARAÑAQUE INVESTMENT and DEVELOPMENT CORPORATION, ROMAN C. TAMAYO, THE COMMISIONER OF THE LAND REGISTRATION COMMISSION and the REGISTER OF DEEDS OF NUEVA ECIJA, respondents. ALIPIO ALINSUNURIN, now substituted by PARAÑAQUE INVESTMENT and DEVELOPMENT CORPORATION, applicant-appellee, vs. THE DIRECTOR OF LANDS, THE DIRECTOR OF FORESTRY and the ARMED FORCES OF THE PHILIPPINES, oppositors-appellants.

FACTS

Alipio Alinsunurin, later substituted by Parañaque Investment and Development Corporation, applied for registration of a 16,800-hectare land in Laur, Nueva Ecija, claiming ownership by inheritance from Maria Padilla, who allegedly inherited it from Melecio Padilla, holder of a Spanish-era possessory information title. The land is within the Fort Magsaysay military reservation established by Presidential Proclamation No. 237 in 1955, is largely uncultivated, mountainous, and forested. The Director of Lands, Director of Forestry, and the Armed Forces of the Philippines opposed the application. The lower court adjudicated the land, ordering its registration two-thirds in favor of Parañaque Investment and one-third in favor of Roman C. Tamayo. The government oppositors filed a notice of appeal. Pending appeal, the lower court directed the issuance of a decree of registration for the entire land, which was implemented, prompting the government to file a special civil action for certiorari and mandamus.

ISSUE

Whether the lower court erred in ordering the registration of the land and in issuing the decree pending appeal.

RULING

The Supreme Court reversed the lower court’s decision and nullified the decree and title. The land, being within a military reservation proclaimed by the President, is part of the public domain and cannot be subject to private appropriation. A possessory information title, without subsequent judicial confirmation, does not constitute incontrovertible evidence of ownership, especially against the state. The applicant failed to prove open, continuous, exclusive, and notorious possession and occupation of the land for the required period under the Public Land Act. The land’s character as forested and within a reservation negates the claim of agricultural use necessary for confirmation of imperfect title. The lower court’s act of ordering the issuance of a decree pending appeal was a grave abuse of discretion, as it effectively executed judgment despite a pending appeal that raised substantial questions of law. The state retains dominion over all lands not conclusively shown to have been privatized in accordance with law.